Sanctions Guide

As a funds transfer operator, Curfex shall ensure the implementation of economic sanctions as dictated in the Foreign Exchange and Foreign Trade Act ('Foreign Exchange Act') in the remittance transfers that we process. Pursuant to the provisions of Article 17 of the Foreign Exchange Act, we endeavour to ensure that our customer remittance transfers are NOT subjected the "Trade Payment Regulations" and "Use of Funds Regulations".

  1. You will be required to declare your purpose of transfer.

    1. If the purpose of transfer is import payment, intermediary trade payment, or similar, you will also be required to provide us with the product/goods, place of origin (country), shipping region (city), destination (country) (in the case of an intermediary trade payment).
    2. Please make sure that your transfer is NOT a “North Korea/Iran restricted transfer” under the Foreign Exchange Act and NOT a Russia-related restricted transfer. You will be required to make a declaration to that effect in the transfer confirmation page.
  2. You will be required to confirm the payee of your transfer. To the best of your knowledge, the final beneficiary of the transfer is NOT a resident of North Korea and/or NONE of the major shareholders or directors of the corporation is a resident of North Korea.
  3. You may be required to present documents to proof and confirm the details of the transfer. When required, we may ask you to send us documents to proof and confirm the details of the transaction. If it cannot be confirmed conclusively that your transfer is NOT a restricted transfer, we reserve the right to reject the transfer.
  4. In regards to Russia-related regulations, please check the Ministry of Finance notices and the Ministry of Finance website for the latest regulations.

Regulations on transfer based on the Foreign Exchange Act (Restricted Transfers Excerpt)

  1. North Korea "Trade Payment Regulations"

    1. Import or intermediary trade of all goods whose origin or shipping area is North Korea (implemented on October 14, 2006)
    2. Intermediary trade for goods destined for North Korea (implemented on June 18, 2009)
  2. North Korea "Use of Funds Regulations"

    1. Conducted for the purpose of contributing to "activities that can contribute to North Korea's nuclear-related programs" (implemented on July 7, 2009)
  3. North Korea "Prohibition of Payments"

    1. Payments to persons who have addresses in North Korea are prohibited in principle, with the exception of those payments of JPY 100,000 or less for humanitarian purposes (implemented on February 26, 2016)
  4. Iran "Use of Funds Regulations"

    1. Conducted for the purpose of contributing to "activities related to Iran's nuclear activities" (implemented on January 22, 2016)
    2. Conducted for the purpose of contributing to "activities related to the supply of large conventional weapons to Iran" (implemented on January 22, 2016)
  5. Russia "Foreign Direct Investment Regulations"

    1. New foreign direct investment in Russia (implemented on May 12, 2022)
    2. Payment of funds for business activities in Russia and when Russian companies, etc. are involved in business activities conducted outside Russia (implemented on May 12, 2022)
  6. Russia and Belarus "Service Transfers Regulations"

    1. Prohibition of servicer transfers (transfer of technology, etc.) to Russia or Belarus regarding regulated items (implemented sequentially from March 8, 2022)
  7. Regulations on Capital Transactions Related to Price Ceilings for Russian Crude Oil

    1. Prohibition of transactions related to the occurrence of claims based on money loan contracts or debt guarantee contracts related to the purchase of crude oil that exceeds the upper limit price of crude oil that originates from Russia and is transported by sea (crude oil: implemented on December 5, 2022; petroleum products: implemented on February 5, 2023 (planned))